Norman John Haas III and Susan Renee Haas - Page 8

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          that the gifts were valued based upon what one would pay at a               
          thrift shop or rummage sale.                                                
               As evidence to substantiate their noncash gifts, petitioners           
          introduced an itemized list of what petitioner testified to be              
          the value of the gifts that they had claimed on their return.               
          Petitioners’ list gave only a general description of the items              
          that they donated.  One of the gift dates on petitioners’ list,             
          April 17, 2001, is not listed on the return.  Petitioners claimed           
          on their return $500 as the value for each of 10 gifts to the               
          Salvation Army.  Aside from the fact that the amounts on                    
          petitioners’ list appear to be inflated, none of them are valued            
          by petitioners at $500.  Each of the three gifts to Sun Cities              
          Animal Rescue is reported on the return at a value of $500, but             
          on the list the gifts are valued at $736, $240, and $388.  The              
          values of the two Goodwill donations on the list, likewise, do              
          not jibe with the amounts on the return.                                    
               While the Court believes that petitioners actually donated             
          the items on the list, petitioners offered no corroborating                 
          evidence that the method they used to value the property was                
          accurate.  The Court finds that petitioners have failed to prove            
          the value of their contributions.  The Court further finds, using           
          its judgment, that the fair market value of the donated property            
          was $2,000.  Petitioners are entitled to a deduction in that                
          amount.  See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.           

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